Beyond Decriminalisation: pregnancy choices and abortion care in Northern Ireland

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Beyond Decriminalisation: pregnancy choices and abortion care in Northern Ireland
Beyond Decriminalisation:
pregnancy choices and
abortion care in Northern Ireland
“The British Society of Abortion Care Providers endorses
     the early medical abortion service being run in Northern
         Ireland and the central access point provided by
     Informing Choices NI. The single phone number helpline
      serves all people in Northern Ireland and facilitates self-
     referral, provides an initial consultation, offers counselling
        if needed, addresses safeguarding and then makes
        referrals to each Health and Social Care Trust. Many
      providers in Great Britain regard this streamlined single
     point of access as an ideal model for efficiency of process
     and responsiveness to patient need. The Northern Ireland
        service specifications are fully compliant with NICE
     recommendations, contraceptive supplies and fitting are
           offered at all clinics and feedback from patient
            evaluations has been exceptionally positive.”

           The British Society of Abortion Care Providers
                             June 2021

02   BEYOND DECRIMINALISATION
Contents
Prologue
My Story: a woman’s experience of accessing local abortion care in Northern Ireland             pages, 4-6

Foreword
The Walls of Silence Surrounding Abortion: learning from the past and looking to the future
by Dr Audrey Simpson OBE                                                                        pages, 7-9

Executive Summary                                                                              pages, 10-13

Chapter 1
Covid-19 and Access to Abortion: the rapid implementation of an EMA service
by Dr Siobhan Kirk                                                                             pages, 14-16

Chapter 2
The Central Access Point: standing by women and girls and all pregnancy choices
by Ruairi Rowan                                                                                pages, 17-21

CAP Referrals by Parliamentary Constituency                                                   pages, 22-23

Chapter 3
The Right to Choose: insights from a counselling service
by Carrie Montgomery                                                                          pages, 24-27

Chapter 4
Working with No Support: the failure to commission abortion services in Northern Ireland
by Dr Sandra McDermott                                                                        pages, 28-31

Chapter 5
Safe Access to Healthcare: the negative impact of anti-choice protestors
by Dr Caroline Hunter                                                                         pages, 32-34

Chapter 6
How to Access Services: the need for a public health information campaign
by Dr Sharon Porter                                                                           pages, 35-36

Chapter 7
Contraception Provision: additional investment to reduce unintended pregnancies
by Dr Eveane Cubitt                                                                           pages, 37-38

Chapter 8
The Commissioning of Services: the role and expertise of NIACT
by Dr Ralph Roberts and Dr Leanne Morgan                                                      pages, 39-41

Epilogue
Decision Time: where next for local services?
by Ruairi Rowan                                                                               pages, 42-43

                                                                            BEYOND DECRIMINALISATION          03
Prologue
     My story:
     a woman’s experience of accessing local abortion care in Northern Ireland

     With Health and Social Care (HSC) Trusts in Northern Ireland now providing early medical abortion (EMA)
     services this article was written by a woman who accessed this healthcare within the South Eastern HSC Trust. It
     recounts her experience and calls on our government to stop adding additional distress and trauma onto people
     in crisis and to commission the abortion services which are now legally provided for.

     Initial shock                                               Just as I hadn’t been aware that a local abortion
                                                                 service existed, I was also unaware that funded travel
     At the end of June of 2020, I found out I was               and treatment was available in England for people
     pregnant. It was a complete shock. When I missed my         living in Northern Ireland. From my conversations
     period, I didn’t think much of it, as it was quite normal   directly with the clinics, I was led to believe that it
     for me and my body. I only took the test because my         would take all of my savings to make the trip,
     partner at the time thought it might be good just to        including the cost of the ferry/inflated covid air travel
     rule it out, and even then, he physically had to buy the    prices, accommodation, and expenses. Even then, it
     test. I took it that evening just to get it over and done   would not have been enough for both me and my
     with. A few moments later, I looked down, expecting         partner to go. The possibility of having to go alone
     the inevitable negative result, to instead see a clear,     was pretty likely.
     dark cross. Before I could even process it, my stomach
     dropped, I began to feel violently ill and dizzy. I could   Telling our parents, which might have given us access
     barely get the words out to get the attention of my         to some money to travel, was not an option either. I
     partner. Even just writing this, my heart is pounding       can only speak for myself, but I know for me, even in
     out of my chest as it was in that moment.                   the privileged position of a good relationship with my
                                                                 parents, I felt so much shame, guilt and
     Immediately I felt an overwhelming sense of shame           embarrassment that I couldn’t fathom having that
     and failure. I’ve always wanted to be a mum, but I          conversation. There was also an element where, as
     knew that I couldn’t put myself and my partner              twenty-something year olds, it felt like something we
     through having a child. We were both nowhere near           needed to emotionally deal with privately, as adults.
     financially stable, barely at the beginnings of our
     careers, and I knew I couldn’t put our families through     Looking back now and being able to remove myself
     being financially and emotionally responsible for a         from the situation, I can also see that it is my right to
     child. Although I knew I was doing the right thing for      keep my healthcare between me and my healthcare
     my family, my partner, and myself, there was no point       provider. Access to that care should in no way rely on
     where it felt an easy decision to make.                     forfeiting that right, or rely on a person having some
                                                                 form of a financial support system already around
                                                                 them in the first place.
     How to access services
                                                                 For a moment in the first couple of days, I considered
     After the initial shock, I began looking into getting an    ordering pills online, although it never really felt like a
     abortion. I can’t lie, at that point I didn’t even know     real choice. How would I know if they were safe? How
     that we had a functioning abortion service in               would I know if they worked? What would happen if
     Northern Ireland, and I started calling abortion clinics    something went wrong? Who was responsible if
     in Manchester. After a few phone calls, it became           something went wrong? Who would check up on
     clear how difficult it would be making that journey.        me? Would there be anyone I could talk to about it?

04    BEYOND DECRIMINALISATION
Finding local support                                       Attending for treatment

As my morning sickness and extreme fatigue set in, I        Soon enough my physical appointment came. I felt
could barely make it past 2pm without needing to            relieved to be pulling up to the hospital I had known
sleep or be sitting down. A couple of nights, I woke        my entire life. I could, for a brief second, pretend like I
up with sharp stabbing pains, and in my sleepy panic,       was going for any other appointment I had had there.
I assumed I was having a miscarriage, and began to          The doctor explained what would happen, and I got
freak out. They subsided, but it didn’t stop me             the opportunity to ask her a couple of questions
imagining being in pain, more physical and emotional        about concerns I had. Then I took the first pill. I came
pain than I was already in, as well as nauseous and         out of there knowing that this was a day I would
hormonal, on a plane; on a ferry in the middle of the       remember for the rest of my life, but feeling like the
Irish Sea, with no idea how or if I can get help. After     end of this terrible period of my life could finally be
doing a bit of research, I managed to get in contact        coming to a close. The next morning, I woke up
with Informing Choices NI (ICNI). There is part of me       feeling, as usual, weighed down by this big heavy
that wants to express how much relief finding them          secret, but also feeling grateful to be in the familiarity
and the services I needed gave me, but I fear that in       of my then partners house and family, even if they
the process, the pain and distress of a situation like      didn’t know what was going on.
this could be lost. Even in my privileged position, this
was easily the worst period of my life, and I can’t         I took the second set of pills that evening. My best
imagine what it could be like for people less fortunate     friend, who I had decided to confide in a few days
and with less support than I had.                           prior, brought me extra thick sanitary towels, and a
                                                            special mat to put down on my bed. I lay in bed that
ICNI arranged for me to have a phone consultation           evening in more pain than I’d ever experienced
with a doctor. Before the appointment, I drove around       before. At one point I was convinced something had
to calm my nerves, but also to find a private space         gone wrong, but even then, all I could think about
where I could take the call, where I could be sure no       was how grateful I was that I knew for certain that the
one could hear or see me. After the phone                   pills I had taken could be trusted, handed to me by a
appointment I was booked in for an appointment at           local doctor, and that the hospital was a phone call
the Ulster Hospital. When I hung up, I sobbed for an        away. It was only a 15-minute drive, and I had a letter
hour. In one sense it was relief, but mostly I was just     explaining to the A&E doctor/nurse what had
extremely sad about what was happening. In the short        happened and who was looking after me. I didn’t
weeks I was pregnant, there was rarely a moment it          have to worry about getting in trouble, I didn’t have
wasn’t on my mind, and if I happened to momentarily         to worry about how I would get from a hotel to a
forget about it, I would quickly be reminded of it with     hospital I didn’t know, or getting into a taxi, or being
excruciating headaches, nausea and fatigue.                 alone.

I cannot express to you how lucky I was at every
single step of this process. I had time to be sick, I had   Post pregnancy counselling
time to rest when I needed it, I had time to hide from
people, so they didn’t figure out what was really           A few hours later, most of the pain subsided. I didn’t
going on. I had enough time on my own that I could          realise how long my whole body had been tense,
do my crying in private, and I didn’t have to hold it       shoulders up to my ears. For the first time in two
together for anyone. I cannot even imagine what it is       weeks, I felt like I could take a full deep breath. The
like for someone to have to continue working, being a       next few days, a few weeks even, were a bit of a blur. I
parent, looking after family members or dealing with        began to struggle, and luckily at that time my
mental or physical health issues. Let alone having to       counselling sessions with ICNI began. I can’t really
emotionally and physically deal with travelling to a        remember much of what I said or felt on those calls,
different country, or the uncertainty of ordering           but I do know that each time I hung up the phone I
medication online.                                          felt some of the burden lift off my shoulders,

                                                                               BEYOND DECRIMINALISATION                   05
especially on the days where I knew if it wasn’t for my
     appointments, I wouldn’t have spoken to anyone that
     day at all. A couple of months later, I started to feel
     better, and like I could start to move on with my life.

     Failure to implement the law

     I remember having my last call with my ICNI
     counsellor, and being able to recognise how different
     I felt from the first time I had spoken to her. I wasn’t
     100% okay, and it was a few weeks later until I really
     felt like my body began to move on too, but I knew I
     really had come to the end of that chapter of my life.
     A painful chapter, that I had the privilege of
     experiencing at home, with my own family, my bed,
     my own surroundings, my local hospital, without
     having to travel to an unfamiliar city, without fear of
     getting pills off the internet. All luxuries I would not
     have been afforded a few months prior, or indeed,
     several months later, when the service in my local
     area was suspended due to a staff shortage. Knowing
     it could have been so much worse, and it has been so
     much worse for so many people before me, less
     privileged than I am, and people since me, while our
     government has failed to put the relevant provisions
     in place, is something I find very hard to come to
     terms with.

     Travelling to another country or ordering pills online
     in order to access basic healthcare is not an option,
     it’s a last resort. I hope that my story can be used as
     example of how difficult this process is for everyone
     in every circumstance. Even further, how utterly cruel
     it is to add additional distress and trauma onto
     people in crisis, due to the failings of our government
     and its duty to implement the law.

06    BEYOND DECRIMINALISATION
Foreword
The Walls of Silence Surrounding Abortion:
learning from the past and looking to the future
by Dr Audrey Simpson OBE

This article begins with a reflective journey of the societal, political and medical context surrounding abortion in
Northern Ireland over the past thirty years. It provides a synopsis of the motivation for a judicial review to secure
guidance for healthcare professionals on the provision of abortion services in Northern Ireland; tracks the legal
challenge led by the Family Planning Association in Northern Ireland (FPA NI) and the outcome and impact of
this case; the eventual closure of FPA NI, and the formation of Informing Choices NI (ICNI). It ends with the
establishment of the central access point (CAP) into early medical abortion (EMA) services in Northern Ireland
and the ongoing challenges in securing reproductive rights for all women and girls.

The walls of silence                                          From the beginning we recognised that it was highly
                                                              unlikely that the courts would extend the Abortion
The 1990’s was a bleak time for abortion rights for           Act 1967 to Northern Ireland so our legal team
girls and women in Northern Ireland. Unlike many              advised that the legal premise with greatest potential
other international countries fighting for reproductive       was to argue that the Department of Health, Social
rights, the women’s movement and human rights and             Services and Public Safety (DHSSPS), as it was then
equality bodies in Northern Ireland were notable by           known, was failing in its statutory duty by not issuing
their silence. Apart from Alliance for Choice there was       official guidance to health professionals on the
no vociferous grass-roots activism and the                    circumstances in which abortion was lawful in
overwhelming majority of those who travelled to               Northern Ireland. It was felt that not only would this
England to secure an abortion did so in silence.              clarify the law, but also importantly, mainstream and
                                                              legitimise abortion services in Northern Ireland.
Furthermore, the main priority for UK Government
was the peace process and restoration of a power-             On 13th June 2001 FPA NI’s application for a judicial
sharing legislature in Northern Ireland. In effect            review was heard in Belfast High Court and leave was
abortion was surrounded by what I called ‘walls of            granted. The full hearing took place on 21st and 22nd
silence’.                                                     March 2002.

Given the political apathy at Westminster and                 Inside the courtroom FPA NI were opposed by five
political vacuum at Stormont for many years FPA NI            legal teams representing three anti-choice
was a lone voice publicly calling for equal access to a       organisations, the Northern Bishops as well as the
healthcare service in Northern Ireland which was              government. Outside the court anti-choice protests
freely available to girls and women in the rest of the        intensified in their numbers including waving placards
UK.                                                           showing distorted images of aborted foetuses and
                                                              false information such as ‘abortion causes breast
                                                              cancer’.
Taking our funders to court
                                                              Levels of harassment against FPA NI increased
We recognised that traditional lobbying and                   substantially. This included following clients attending
campaigning activities were not achieving significant         our pregnancy counselling service, and staff, to their
change which left only one further option, to explore         cars and shouting at them in the streets. Leaflets
the potential of the judicial system to affect real           were thrown through car windows some of which
change in securing abortion rights.                           stated that women who had been raped couldn’t

                                                                                BEYOND DECRIMINALISATION                 07
become pregnant as the trauma of the rape would           The legal challenge attracted considerable media
     prevent conception. On one occasion there was a           attention which stimulated a public dialogue around
     mock funeral outside our premises with protestors         reproductive rights in Northern Ireland. The
     wearing black robes, black tears painted on their         legitimising of the issue ‘gave permission’ for health
     faces, carrying a child’s white coffin whilst chanting,   professionals to speak openly for the first time about
     ‘Hey, hey FPA how many kids have you killed today?’       the impact of the absence of official guidance for
                                                               their clinical practice. Women’s groups and human
     Judgement was finally given in the legal case on July     rights and equality bodies initiated their own
     7th 2003. The presiding judge, Mr Justice Kerr, ruled     campaign activities to support girls and women in
     that the DHSSPS was not failing in its statutory duty     Northern Ireland. There was growing support among
     to issue guidelines but thought it would be prudent if    Northern Ireland politicians but most important of all
     they did so. (Justice Kerr was latterly appointed to      girls and women felt empowered to join in the public
     the UK Supreme Court and fifteen years later would        debate by recounting their experiences when faced
     rule that Northern Ireland’s abortion law constituted a   with a crisis pregnancy. Lastly the guidance
     breach of women’s human rights).                          document endorsed FPA NI’s long standing
                                                               argument that abortion was indeed legal in Northern
     Following his somewhat ambiguous decision on this         Ireland. But more was yet to come!
     occasion papers were lodged by FPA NI on 28th July
     2003 appealing the outcome and a hearing was
     eventually heard by a panel of three judges from the      Renewed campaigning and
     24th to 26th of May 2004. On October 8th of that          new challenges
     year the Court of Appeal ruled in favour of FPA NI
     and ordered the DHSSPS to consider what steps it          FPA NI continued to campaign for further reform
     should take to fulfil its duties by carrying out an       including the decriminalisation of abortion. A strong
     investigation and issuing appropriate guidance.           effective partnership was formed with Amnesty
                                                               International UK who like FPA NI had a significant
                                                               presence at Westminster. We worked with the
     The long wait for guidance                                Northern Ireland Women’s European Platform and
                                                               Alliance for Choice to prepare a submission to the
     In 2005 DHSSPS set up a working group to take the         United Nations Committee for the Elimination of
     process forward which included a workshop for             Discrimination Against Women (CEDAW) requesting
     healthcare professionals and circulating a                an inquiry into access to abortion in Northern Ireland.
     questionnaire to the Chief Executives of the Health       Ultimately the findings of this inquiry provided the
     and Social Care (HSC) Trusts, GPs, gynaecological         basis of the legislation to reform abortion law in
     nurses, midwives and obstetricians. Unbelievably it       Northern Ireland in July 2019.
     took twelve years to complete the process, fifteen
     years from the beginning of the judicial review           Regretfully FPA NI as an organisation was not around
     challenge.                                                to celebrate this historic change. In May 2019 the
                                                               London based Trustees of FPA UK placed the
     After numerous delays and attempts by anti-choice         organisation into voluntary administration which
     organisations through the courts to prevent               meant that FPA NI no longer had any legal identity.
     publication, finally on 25th March 2016 the Northern      Now retired I was immensely proud when the staff
     Ireland Executive approved ‘Guidance for Health and       asked me to work with them to form a new
     Social Care Professionals on Termination of               organisation, ICNI, and by the end of May this had
     Pregnancy in Northern Ireland’.                           been legally constituted and I had the honour of
                                                               becoming Chair of the Board of Trustees.
     Although it took an interminable length of time to
     accomplish what we set out to do I am proud of what       The biggest challenge facing ICNI was, and as this
     was achieved throughout those long fifteen years.         report demonstrates, continues to be, ensuring that

08    BEYOND DECRIMINALISATION
the decriminalisation of abortion and the new               Northern Ireland. It is also a celebration of what has
framework for services is put into practice. Covid-19       been achieved since decriminalisation. Whilst not
created its own challenges but despite this and the         advocating dwelling on the past I believe at times it is
lack of political enthusiasm for commissioning              important to reflect on how far we have travelled and
abortion services, girls and women, through the             the lessons learned. In so doing it will remind us that
commitment of local healthcare professionals are            anything is possible.
accessing abortion services in Northern Ireland. ICNI
has played a significant part in this by establishing the   Finally, I have to admit that in June 2001 when I
CAP service into local EMA care.                            began the judicial review process, I never thought I
                                                            would be writing about inconsistent abortion service
At the time of publication, the Department of Health        provision in Northern Ireland and campaigning for
and the Northern Ireland Executive is refusing to           appropriate commissioning of services!
commission full abortion services throughout
Northern Ireland. This has resulted in inconsistent
provision and ICNI struggling to sustain and develop
the CAP service.

As an organisation we are fully committed to
ensuring that no woman or girl is forced to leave
Northern Ireland to access abortion care that should
be available locally. I would like to take this
opportunity to thank the staff of ICNI for putting that
commitment into practice. Without their willingness
to assume additional responsibilities, negotiate the
challenges of working in a pandemic, work additional
hours and forego annual leave, the CAP service
would never have evolved.

This service has now been in operation for 14 months.
During this time ICNI have made repeated attempts
to engage with the Health Minister about the
sustainability and development of the service,
including the funding required. Throughout the
course of this correspondence, we have repeatedly
made clear that an unfunded service of this scale
cannot run indefinitely. Despite these repeated
warnings we have received no response from the
Minister. As a small charity with limited resources and
staff the provision of this vital service has placed
considerable pressures which we cannot continue to
absorb. As a result, the ICNI Board of Trustees have
reluctantly taken the very difficult decision that if
funding is not made available for the service to
continue, we will cease providing it from 1 October
2021.

This report will address the impact that the
withdrawal of the CAP service would have alongside
the ongoing challenges in securing abortion rights in

                                                                              BEYOND DECRIMINALISATION                 09
Executive Summary

     Introduction                                                women and girls self-referred with an unplanned or
                                                                 crisis pregnancy. The average age of those who
     On 22 October 2019 abortion was decriminalised in           sought support was 29. The parliamentary
     Northern Ireland and the Abortion (Northern Ireland)        constituency with the highest number of referrals was
     Regulations 2020 came into force from 31 March              North Belfast.
     2020. The new Regulations coincided with a global
     health pandemic as a result of the outbreak of Covid-
     19. Due to the lack of flights, the only option available   Pregnancy counselling support
     to women was to undertake an eight-hour ferry
     journey to England before further onward travel to a        As highlighted in chapter three ICNI’s post
     clinic. Effectively, women from Northern Ireland            pregnancy counselling service offers support on a
     accessing abortion services needed to spend three           wide range of pregnancy related issues – pregnancy
     days – including up to 24 hours on public transport –       loss, either through miscarriage, stillbirth or abortion –
     travelling to access care during a pandemic while the       a traumatic birth or postnatal depression or anxiety.
     general public was being advised to stay at home.           This service has seen an 85% increase in demand
                                                                 since April 2020 compared to the previous six
                                                                 months preceding the launch of the CAP service. One
     Rapid implementation                                        in thirty women who have requested access to
     of EMA services                                             abortion care during this past year have referred into
                                                                 ICNI’s post pregnancy counselling service for support
     As chapter one outlines, continuing to expect               following treatment.
     women to undertake such journeys was neither a safe
     or reasonable option. As a result, a safe, accessible       Women may have conflicted feelings following the
     early medical abortion (EMA) service, with robust           loss of a pregnancy by abortion and even when they
     clinical governance, was developed within a matter of       don’t feel conflicted or experience any emotional
     days and integrated into existing sexual and                tension around their decision to end a pregnancy,
     reproductive health services within Health and Social       simply experiencing a stressful situation can trigger
     Care (HSC) Trusts in Northern Ireland.                      feelings of anxiety, panic or depression. For the
                                                                 majority of women who seek support following an
     Many willing staff had previous experience of               abortion, it is more often for the existing stressors in
     abortion care from working in other parts of the UK         their life which have been exasperated by a
     and peer support and training was offered. Clinic           crisis/unplanned pregnancy than for grief in relation
     protocols and other necessary documentation was             to the pregnancy loss itself.
     rapidly designed. As discussed in chapter two,
     Informing Choices NI (ICNI) agreed to provide an            It is not uncommon for a stressful situation to trigger
     interim central access point (CAP) service into local       previous traumas and for example one third of
     EMA care. This enables people from across Northern          women who have referred into the service have been
     Ireland to contact a single telephone number – 028          impacted by historical sexual abuse/violence and this
     9031 6100 – where they can also access non-directive        is first time they have been offered a supportive
     information, pregnancy choices counselling if               space where they can discuss these traumas. At the
     requested, and referral into an EMA service within          time of reporting twenty-two people are currently on
     their HSC Trust. A medical consultation is offered          a waiting list for post pregnancy counselling, with the
     within a few working days, and a time is then agreed        average waiting time of two-three months for new
     to attend a clinic for treatment.                           referrals received.

     In the first year of providing the CAP service 2182

10    BEYOND DECRIMINALISATION
The precarious provision                                   situation has been described by women as a
of local services                                          ‘disaster’. Often, they ask why, if the law has changed,
                                                           are services not in place. Others asked if they lived in
Since the introduction of the new Regulations, it has      another area, or had called sooner would they have
been left to individual HSC Trusts and ICNI to absorb      been able to access the service locally. In most cases
the needs of women, and without additional                 the answer to both of those questions was yes. This
resources we have seen the services struggle to cope.      answer has caused those women particular upset.
On Monday 5 October 2020 the Northern HSC Trust
ceased providing their EMA service. As a result,           When informed of the current options available to
people living within this area had their options limited   them when requesting access to abortion, the vast
to traveling to England through the UK Government          majority of women opt for accessing the medication
funded central booking system; travelling to the           online. They state that travel, particularly during a
south of Ireland and paying privately to access            global health pandemic, is not ‘feasible’ or ‘practical’,
abortion care at a cost of around ¤450; or accessing       with some describing the idea of travel as ‘scary’
medication outside of NHS/HSE provision through            during the current climate. Some women have stated
independent online telemedicine providers such as          that accessing pills online is not how they would have
Women Help Women or Women on Web.                          preferred to access abortion care, but that they have
                                                           been left with no other choice.
The service in the Northern HSC Trust was
subsequently reinstated on 4 January 2021. The
following day the South Eastern HSC Trust                  Safe access to healthcare
suspended their EMA service. As a result of the
suspension women and girls living within this area         Unfortunately, women accessing abortion services
faced the same limited options as outlined above.          across Northern Ireland have come into contact with
The service was subsequently reinstated on 1               anti-choice protest groups who have caused
February 2021.                                             considerable distress. As outlined in chapter five
                                                           there is no evidence that their presence outside
On 23 April 2021 the Western HSC Trust suspended           healthcare facilities is preventing abortion, which is
their EMA service which had been maintained over           what they claim to want to achieve, it seems more
the past year by a single doctor working without any       likely that there may be an increase in morbidity
support. In chapter four the doctor has written a          caused by later presentations to the service and
personal account of her experience in which she            reluctance to avail of medical follow up. As lockdown
describes the past year as the most rewarding of her       measures ease their activities could increase which
thirty-seven-year career. However, she also states it      will cause additional harm to patients and negatively
has been the most stressful and easily the loneliest. At   impact on the legal provision of healthcare services. It
the time of publication, the service remains               is clear that in order to protect patients and staff safe
suspended.                                                 access zones should be introduced around sexual
                                                           and reproductive health services and pregnancy
141 people living in the Northern, South Eastern and       counselling centres.
Western HSC Trust areas self-referred into the CAP
service between October 2020 and May 2021 and
requested access to abortion whilst the EMA service        Lack of information
within their HSC Trust was suspended and there was
no local service in which they could receive the care      It has become clear over the past year of EMA
they needed and are legally entitled.                      provision in Northern Ireland, that women and girls
                                                           are signposted to the CAP service via a number of
Women were often very distressed when informed             sources and this is expanded upon in chapter six.
that a service was not available due to the area they      Due to the absence of a formally commissioned
resided in. Some have been very distressed. The            framework, there has been no public health

                                                                              BEYOND DECRIMINALISATION                 11
information campaign to direct women seeking               recommendations in total covering the topics of
     information regarding their pregnancy options              Relationships and Sexuality Education (RSE), sexual
     and/or abortion care away from rogue agencies and          and reproductive health services, contraception
     to the CAP service.                                        provision, abortion access and exercising
                                                                conscientious objection.
     Pregnant women and girls seeking healthcare
     support will generally either search online or contact
     their GP. Those who first contacted their GP Practice      The future of the CAP service
     prior to contacting ICNI have reported a range of
     experiences. The majority indicated that their GP          The CAP service has now been in operation for 14
     reported either not being aware of how to access the       months. During this time ICNI have made repeated
     local services or not being aware of the existence of      attempts to engage with the Health Minister about
     the local service at all. Some reported that their GP      the sustainability and development of the service,
     took the time to seek out the information for them,        including the funding required. Throughout the
     some directed to abortion providers based in Great         course of this correspondence, we have repeatedly
     Britain, others reported that they were advised to         made clear that an unfunded service of this scale
     “Google it” whilst some stated that their GP advised       cannot run indefinitely. Despite these repeated
     that it was “nothing to do with them”. A sizeable          warnings we have received no response from the
     minority who contacted their GP for signposting to         Minister. As a small charity with limited resources and
     the local abortion service reported that this was a        staff the provision of this vital service has placed
     negative experience. They stated it was clear that the     considerable pressures which we cannot continue to
     GP “disapproved” of their decision which left them         absorb. As a result, the ICNI Board of Trustees have
     feeling “judged”. A small number reported that their       reluctantly taken the very difficult decision that if
     GP actively tried to convince them to change their         funding is not made available for the service to
     mind.                                                      continue, we will cease providing it from 1 October
                                                                2021.

     Access to contraception                                    Therefore, the report concludes with an epilogue
                                                                which highlights the implications if funding is not
     Women who access the EMA service in Northern               secured in the coming weeks to enable the CAP
     Ireland are either offered a long-acting reversible        service to continue. Without the service in place, it
     contraception (LARC) method at the same time as            would be left to each HSC Trust to provide their own
     attending for an abortion or they are fast tracked into    pathway into EMA services. This will have financial,
     the service depending on the HSC Trust area they           staffing and training implications for each HSC Trust.
     reside in. Chapter 7 focuses on how added
     investment and promotion of contraception services,        Three out of the five HSC Trusts have suspended their
     in particular a form of LARC, will reduce the number       EMA services to date and this additional strain could
     of unintended pregnancies and improve health               facilitate the collapse of, or severe disruption to, other
     outcomes for women and girls.                              EMA services which heavily rely on ICNI with no
                                                                means to replace the support.

     Commissioning of services                                  Centralising the service within ICNI removes service
                                                                duplication amongst the various HSC Trusts and
     Chapter 8 discusses the formation of the Northern          offers the most cost-effective service. ICNI have a
     Ireland Abortion and Contraception Taskgroup               proven track record of delivering these services and
     (NIACT) and their vision for the future, including their   are a trusted source of information and support for
     recent report on Sexual and Reproductive Health in         women and healthcare professionals.
     Northern Ireland. This report provides a blueprint for
     the commissioning of services and makes 38                 The provision of non-directive information and

12    BEYOND DECRIMINALISATION
pregnancy counselling are neither ‘cross-cutting’ or
‘controversial’ and do not require agreement from the
Northern Ireland Executive. If the Health Minister
wanted to provide the additional resources needed to
ICNI in order to prevent the collapse of the CAP
service he could do so. If he refuses to provide the
urgent and essential funding required the Secretary
of State should direct him to do so. Such action
would aid a regional gold standard information,
support and referral service which will benefit
women, girls and their families and enable them to
experience positive mental health and emotional
wellbeing.

Much positive change has occurred over the past
year. Now is the time to keep moving forward, not
take a step back. We must move beyond
decriminalisation and not only remove the walls of
silence surrounding abortion, but also the walls of
access.

                                                        BEYOND DECRIMINALISATION   13
Chapter 1
     Covid-19 and Access to Abortion:
     the rapid implementation of an EMA service
     by Dr Siobhan Kirk

     On the 31st March 2020 the Abortion (Northern Ireland) Regulations 2020 took effect and on 10th April 2020
     the first early medical abortion (EMA) treatments under the new Regulations took place. Five days later
     Informing Choices NI (ICNI) launched a regional central access point (CAP) service into which women across
     Northern Ireland could self-refer. The rapid implementation of this service occurred outside of a commissioned
     framework and was only made possible by a small team of dedicated professionals committed to ensuring that
     women could access high quality abortion care during a global pandemic. This article outlines how such
     provision was made possible.

     Planning for services                                      Rapid implementation

     Following the decriminalisation of abortion in             Setting up an abortion service in Northern Ireland was
     October 2019, Doctors for Choice NI, a recently            always going to be challenging but we had to develop
     formed pro-choice group of clinicians, started a           a safe, accessible service with robust clinical
     process of engagement with healthcare professionals        governance within a matter of days. Approval was
     around the provision of abortion services in Northern      sought at Chief Executive level within the HSC Trusts
     Ireland. In January 2020 they held a conference in         and after some initial confusion the Chief Medical
     collaboration with Ulster University entitled, “Shaping    Officer, Michael McBride, confirmed on the 9th April
     the future of women’s sexual and reproductive health       2020 that healthcare professionals could legally
     in NI”. This provided valuable networking for              provide abortion care in line with the new Regulations.
     interested health professionals and other agencies,
     such as ICNI, and resulted in the development of the       Many willing staff had previous experience of
     Northern Ireland Abortion Contraception Taskgroup          abortion care from working in other parts of the UK
     (NIACT).                                                   and peer support and training was offered. The
                                                                British Society of Abortion Care Providers (BSACP)
     When the first UK lockdown and travel restrictions         enabled access to training webinars, and the British
     were introduced on the 23rd March 2020, and with           Pregnancy Advisory Service (BPAS) shared their
     the new Regulations coming into effect eight days          patient information and consent forms.
     later, NIACT quickly held their first virtual meeting to
     discuss the possibility of implementing a temporary        Clinic protocols and other necessary documentation
     local EMA service (up to 9 weeks and 6 days                was rapidly designed and shared between HSC
     gestation).                                                Trusts and to fulfil legal requirements a standardised
                                                                notification and certification form was utilised.
     Continuing to expect women to travel to England in
     the midst of a pandemic was not a safe or reasonable       Sexual and reproductive health services in Northern
     option and the plan was for EMA treatment to be            Ireland use Lilie – an online IT system – and templates
     offered within existing sexual and reproductive health     for EMA telephone consultations, treatments, and
     services where possible. This was only feasible due to     reviews were designed and added by the system
     the downturn in normal work schedules due to               administrator in each HSC Trust.
     Covid-19 and initially only in the Belfast, Northern and
     Western Health and Social Care (HSC) Trust areas.          A referral pathway was developed in partnership with
                                                                ICNI who kindly agreed to provide the CAP service.

14    BEYOND DECRIMINALISATION
Pharmacy links were established to order the new             heightened activity was as a result of people being
medication -mifepristone, misoprostol, analgesia and         redirected from the central booking system, then
anti-emetics. This was not straightforward as most of        operated by BPAS, as well as from online telemedicine
the medication required over-labelling (repackaging          providers, due to the fact that services were now
and labelling with dosage instructions, batch number         being delivered on the ground in Northern Ireland.
and expiry date by the hospital pharmacy
department). A secure controlled drug cupboard was           There is no doctor working in the sexual and
also required for storage along with a record book.          reproductive health service in the Southern HSC Trust
                                                             and most nurses had been redeployed as a result of
Low sensitivity pregnancy tests were sourced and             Covid-19. However, following communication from
ordered. These are provided to patients to take              NIACT, ICNI and other HSC Trust Chief Executives
between two and three weeks after their treatment            their service commenced in May 2020.
to confirm that the medication has been effective.
Links were also made with Early Pregnancy Clinics in         The Belfast HSC Trust was responsible for
each HSC Trust to facilitate referral if necessary, as not   contraception provision for people living in the South
all services were able to offer in-clinic scanning if        Eastern HSC Trust until October 2020, however due
clinically required to confirm gestation, exclude            to the dedication of a Consultant in Obstetrics and
ectopic pregnancy or access follow up care.                  Gynaecology and a few committed colleagues a
                                                             service within this HSC Trust commenced mid-June
In the Belfast HSC Trust a mobile phone was                  2020. This meant all five HSC Trusts now had their
requested to offer patient support during clinic hours       own EMA service.
as a back up to the contact details provided in the
patient information leaflet. This enables patients to        One of the advantages of EMA provision being
contact us if their pregnancy test remained positive         located within sexual and reproductive health
or they had any other concerns. All HSC Trusts offer         services is immediate access to contraception. In the
similar telephone support.                                   Belfast HSC Trust 71% of women referred in 2020 had
                                                             not been using any method of contraception and 15%
One obstacle in the beginning was obtaining a Health         conceived on oral contraception. At some clinics all
and Care Number for women not registered with a              methods of contraception, including immediate
GP in Northern Ireland - a requirement on the                implant insertion, or a fast-track coil appointment are
notification forms. This has since been streamlined          available. As a result, uptake of long-acting reversible
and now easily obtained in most cases.                       contraception (LARC) is high, 55% in the Belfast HSC
                                                             Trust in 2020, with 28% opting for a subdermal
                                                             implant, the most effective form of LARC.
Services commence

Belfast staff initially agreed to treat women from the       Positive feedback
South Eastern and Southern HSC Trusts until services
within those areas could be established. The first           Patient feedback has been excellent with women
EMA treatments under the new Regulations took                delighted to have safe local access to abortion.
place on the 10th April 2020, Good Friday, in the
College Street clinic in Belfast and ICNI launched the       “Everything you did for me was perfect and I would
regional CAP service on the 15th April 2020.                 like to thank you for your help.”

Training to staff in other HSC Trusts was offered within     “I thought the whole process was so smooth. All staff
the Belfast clinic which was initially running five days a   on the phone and face to face were so professional
week due to the level of demand and necessity to             and friendly. Thank you so much.”
cover three HSC Trust areas. 77 people self-referred
into the CAP service in the opening week – this

                                                                               BEYOND DECRIMINALISATION                 15
“Thank you for your help during this difficult time. A     Waiting times are low, allowing safer treatment at
     very valuable, excellent service.”                         earlier gestations. Due to the small number of
                                                                dedicated people involved, from ICNI and the HSC
     “All people really lovely, especially my doctor, she       Trusts, we have a very effective team with excellent
     really put my mind at peace.”                              communication, and this has optimised patient care.

     “Very nice and helpful and helped me to choose the         We have monthly Clinical Lead meetings with the
     right contraception.”                                      ICNI team for support and service updates and a
                                                                regional clinical WhatsApp group for medical queries.
     “Everyone has been very helpful and easy to talk to
     about my situation. It makes all the difference at a       EMA staff have found this new role challenging but
     difficult time.”                                           also immensely rewarding. Hopefully commissioning
                                                                will happen soon and both ICNI and the HSC Trusts
     “Excellent service! I was really happy with the doctor,    will get the funding and support they urgently need
     facilities and treatment.”                                 and deserve.

     “Very friendly and professional. I was very pleased
     with the nurse who looked after me.”

     “The doctor was excellent in her professionalism and
     explanation of everything. So glad this service is now
     available in Northern Ireland. Thank-you.”

     Failure to commission services

     However, due to the ongoing lack of commissioning
     or funding the services are extremely fragile – three of
     the five HSC Trusts have temporarily suspended
     services to date - we have no surgical treatment for
     those who would prefer this option and there is no
     pathway to care for women over 10 weeks gestation.

     Unfortunately, at home mifepristone has not yet been
     allowed in Northern Ireland necessitating a clinic visit
     for all women, unlike in the rest of the UK and Ireland
     where full telemedicine is available temporarily due to
     Covid-19. Despite lockdown restrictions, clinics are
     also experiencing increasing protests from anti-
     choice organisations.

     Overcoming obstacles

     Notwithstanding the challenges, we have
     demonstrated that safe local abortion care can be
     delivered within sexual and reproductive health
     services with the support of ICNI providing the CAP
     service.

16    BEYOND DECRIMINALISATION
Chapter 2
The Central Access Point:
standing by women and girls and all pregnancy choices
by Ruairi Rowan

“Should a woman want to access abortion services, she can contact her GP in the first instance or she can
contact Informing Choices NI.” – Robin Swann MLA, Health Minister

The words above were spoken by the Health Minister, Robin Swann MLA, in the Northern Ireland Assembly in
March 2021. In doing so he was signposting women to a service which thus far his Department has refused to
commission. How did such a scenario come into being? This article builds on the foreword written by Dr Audrey
Simpson and focuses on the closure of the Family Planning Association (FPA), the emergence of Informing
Choices NI (ICNI) and the launch of a ground breaking non-commissioned service that has supported over 2000
women and girls with an unplanned or crisis pregnancy during the past year.

The end of an era                                          matter of weeks to agree, ended up with protracted
                                                           conversations with funders and the liquidators
On 30 April 2019 I sat in the former FPA office in         spanning six months and where my resilience as a
Belfast alongside all my colleagues from Northern          campaigner proved beneficial.
Ireland. Three non-staff members were in the room.
One was the former FPA NI Director, Dr Audrey              One thing that did proceed with pace was the
Simpson, the other two belonged to an organisation         recruitment of a new Board of Trustees with Dr
called RSM, an audit, tax and consulting firm, who         Audrey Simpson as chair-elect. This was one of the
had been instructed by the London based FPA Board          reasons why she was in attendance during the
of Trustees to place the charity into what is known as     meeting with the representatives from RSM.
a Creditors’ Voluntary Liquidation.
                                                           Following that meeting I called my colleague and
The Trustees, concerned by a long-standing final           friend Grainne Teggart. Grainne is the Campaigns
salary pension repayment commitment, had taken             Manager for Amnesty International in Northern
the shocking decision to close the charity. All staff      Ireland and together we had formed a strong
were being made redundant and 90 years of history          partnership and had a significant presence at
was coming to an end in two weeks. As a result, the        Westminster in the lead up to Northern Ireland’s
organisation which had led the charge on securing          abortion law finally being changed. I updated her on
abortion rights in Northern Ireland wasn’t there to        the situation with FPA, which was initially met with
witness the change.                                        shock, and our plans to reform as a new organisation.
                                                           She immediately agreed to become a Trustee.

New beginnings                                             My next call was to the leader of the Green Party in
                                                           Northern Ireland, Clare Bailey MLA. I asked if she was
The next few months were tough and often it felt like      free and made the short walk from the FPA office in
we were taking one step forward and two steps back.        Shaftesbury Square to her constituency office on
Forming a new organisation may sound glamorous,            University Street. I relayed a similar account of the
but try opening a bank account and you’ll quickly          situation with FPA and discussed our future
discover how difficult things can be. ICNI eventually      intentions. Clare too agreed to become a Trustee and
managed to maintain all contracts previously held by       assist in any way she could.
FPA NI. However, what we had hoped would take a

                                                                             BEYOND DECRIMINALISATION               17
An hour after the meeting with RSM and we now had        In the lead up to the Abortion (Northern Ireland)
     three new Trustees. Within 24 hours four more had        Regulations 2020 coming into force on 31 March
     been recruited. Professor Bill Rolston, a founding       2020 ICNI experienced a growing number of calls to
     member of the Northern Ireland Abortion Law              our sexual health helpline with people struggling to
     Reform Association; Dawn Purvis, a former MLA and        access abortion care in England due to Covid-19
     Programme Director of Marie Stopes International in      travel restrictions, flight cancellations and hotel
     Northern Ireland; Mary Crawford, the former Director     closures.
     of Brook in Northern Ireland; and Georgie
     McCormick, who established FPA NI’s pregnancy            Due to the lack of flights, the only option available to
     counselling service.                                     women was to undertake an eight-hour ferry journey
                                                              to England before further onward travel to a clinic.
     This group of individuals, alongside the remaining       Effectively, women from Northern Ireland accessing
     staff team, held much of the history associated with     abortion services needed to spend three days –
     FPA NI and the role it played in contributing to the     including up to 24 hours on public transport –
     improvement and change in societal attitudes             travelling to access care during a pandemic while the
     towards sexual and reproductive health and their         general public was being advised to stay at home.
     support was crucial in continuing this work and
     supporting it to evolve.                                 As a result, ICNI worked alongside healthcare
                                                              professionals and members of the Northern Ireland
     We held our inaugural meeting of the new Board of        Abortion and Contraception Taskgroup (NIACT) to
     Trustees the following week and had some good            establish an interim EMA service which was
     news to report regarding donations received,             integrated into existing sexual and reproductive
     including a sizable contribution from the British        health services in Health and Social Care (HSC) Trusts
     Pregnancy Advisory Service (BPAS). This enabled us       in Northern Ireland.
     to retain our premises and a small staff team during
     the transition period and I’ll always be grateful to
     them, and their then Chief Executive Ann Furedi, for     CAP service
     the support provided to get ICNI off the ground.
                                                              A vital part of this process is the ease of the referral
     ICNI were registered with Companies House on 20          pathway through the central access point (CAP)
     May 2019 and work continued over the next few            service provided by ICNI. This enables people from
     months to retain our sexual health helpline, pregnancy   across Northern Ireland to contact a single telephone
     counselling service, Relationships and Sexuality         number – 028 9031 6100 – where they can also
     Education (RSE) programmes, RSE training courses         access non-directive information, pregnancy choices
     and wider advocacy work in relation to sexual and        counselling if requested, and referral into an EMA
     reproductive rights and education services.              service within their HSC Trust. Access to follow up
                                                              support is also available via our post pregnancy
                                                              counselling service.
     Launch of ICNI
                                                              In addition, ICNI undertakes all safeguarding with girls
     With all funding in place and services retained by the   aged between 13-15 years-old and assess their ability
     end of 2019 we officially launched the organisation in   to consent to medical treatment using the Fraser
     January 2020. At this point abortion had been            guidelines. We refer daily to the HSC Trusts, a medical
     decriminalised in Northern Ireland and a consultation    consultation is offered within a few working days, and
     on a new legal framework had been conducted. The         a time is then agreed to attend a clinic for treatment.
     first case of coronavirus had also been reported and     Clients value the service provided by ICNI as is
     it was to be this emerging global health pandemic        highlighted by the feedback from patient evaluation
     that led to the rapid implementation of early medical    surveys:
     abortion (EMA) services in Northern Ireland.

18    BEYOND DECRIMINALISATION
“Informing Choices were the only people to help me        Hokey-Cokey healthcare
get the proper services and help.”
                                                          Since the introduction of the abortion Regulations, it
“Fantastic service, put me at ease from the very first    has been left to individual HSC Trusts and ICNI to
phone call.”                                              absorb the needs of women, and without additional
                                                          resources we have seen the services struggle to cope.
“I was very nervous making the call but the people I
spoke to were very reassuring and I never once felt       On Monday 5 October 2020 the Northern HSC Trust
judged.”                                                  ceased providing their EMA service. They stated that
                                                          they were unable to continue to deliver the unfunded
“Very helpful and comforting. They ensured I              service and as other HSC Trusts did not have the
understood what was being said and made the               capacity to accommodate women who fell within this
situation easier.”                                        area a pathway to care was no longer available to all
                                                          women in Northern Ireland.
“Really informative and explained the process
thoroughly.”                                              As a result, people living within this area once again
                                                          had their options limited to traveling to England
“So professional and instantly made me feel at ease       through the UK Government funded central booking
and reassured.”                                           system; travelling to the south of Ireland and paying
                                                          privately to access abortion care at a cost of around
In the first year of providing the CAP service 2182       ¤450; or accessing medication outside of NHS/HSE
women and girls self-referred with an unplanned or        provision through independent online telemedicine
crisis pregnancy. The average age of those who            providers such as Women Help Women.
sought support was 29. The parliamentary
constituency with the highest number of referrals was     The fact that women were being denied access to
North Belfast. (A full breakdown by constituency          local healthcare based on their location was grossly
follows this chapter).                                    unfair and it was left to ICNI to inform them of this
                                                          and the options available to them.
As expected, the provision of the CAP service has
impacted upon the demand for ICNI’s pregnancy             The service in the Northern HSC Trust was
counselling service with requests for post pregnancy      subsequently reinstated on 4 January 2021. The
counselling increasing by 85% since April 2020            following day the South Eastern HSC Trust
compared to the previous six months before the            suspended their EMA service stating unforeseen
service launched. ICNI applied for a community grant      circumstances resulting in no senior medical cover. As
to enable the organisation to increase our counselling    a result of the suspension women and girls living
support in order to deliver twenty post pregnancy         within this area faced the same limited options as
counselling sessions per week. Additional pregnancy       outlined above. The service was subsequently
choices counselling sessions are provided when            reinstated on 1 February 2021.
requested. However, this is only a short-term solution
which will not sustain the current level of counselling   113 people living in the Northern and South Eastern
requests going forward. At the time of reporting          HSC Trust areas self-referred into the CAP service
twenty-two people are currently on a waiting list for     between October 2020 and January 2021 and
post pregnancy counselling, with the average waiting      requested access to abortion and there was no local
time of two-three months for new referrals received.      EMA service in which they could receive the care they
No one is waiting for pregnancy choices counselling.      needed and are legally entitled.

                                                          Women were often very distressed when informed
                                                          that a service was not available due to the area they
                                                          resided in. The situation has been described by

                                                                            BEYOND DECRIMINALISATION               19
women as a ‘disaster’. The majority of women had             and physical toll on her which could no longer be
     not been aware that the service was suspended                sustained. At the time of publication, the service
     before calling ICNI and many were extremely upset            remains suspended. During the first six weeks that
     and angry when informed of this and said it was              the service was suspended, 26 April – 30 May, 28
     ‘unfair’.                                                    people were impacted.

     Some often ask why, if the law has changed, are              Therefore, three out of the five HSC Trusts have
     services not in place and expressed concern for other        suspended their EMA services in Northern Ireland
     women and girls faced with a similar situation. Others       during a six-month period, and without additional
     asked if they lived in another area, or had called           funding in place the CAP service could be the next to
     sooner would they have been able to access the               face withdrawal.
     service locally. In most cases the answer to both of
     those questions was yes. This answer has caused
     those women particular upset.                                Service development or
                                                                  withdrawal?
     When informed of the current options available to
     them when requesting access to abortion, the vast            ICNI stepped in to provide an interim referral pathway
     majority of women opt for accessing the medication           and additional counselling support as an emergency
     online. They state that travel, particularly during a        response to Covid-19 and by doing so ensured that
     global health pandemic, is not ‘feasible’ or ‘practical’,    there was no delay in EMA services being established
     with some describing the idea of travel as ‘scary’           in Northern Ireland.
     during the current climate.
                                                                  We have highlighted how a service can operate, the
     Women have mentioned that accessing abortion pills           willingness of healthcare professionals in Northern
     online would save an already stretched health service        Ireland to provide the service and the numbers
     money, whilst other women have raised concerns that          availing of it. Most importantly we assisted with the
     they would not be able to afford the donation to             provision of a vital local service to women and girls
     access the pills online despite this being their             during a global health pandemic. Such a ground-
     preference. I am worried that such women will be so          breaking service would not have been possible
     desperate and may turn to more dangerous                     without our involvement.
     methods.
                                                                  However, an essential service of this scale cannot
     Women ask a number of questions regarding online             continue to function without additional resources and
     medication, with the main questions being are they           the current CAP service has only been maintained as
     safe to take, is it legal to access the medication in this   staff have worked additional hours and foregone the
     way, as public prosecutions of others who have done          majority of their annual leave. Without additional
     so are still fresh in many people’s minds, and are they      funding in place the service will be forced to cease on
     able to access medical support afterwards if                 1 October 2021.
     necessary. Some women have stated that accessing
     pills online is not how they would have preferred to         In their recently published, ‘Monitoring Report on
     access abortion care, but that they have been left           Reproductive Healthcare Provision in NI’ the Northern
     with no other choice.                                        Ireland Human Rights Commission (NIHRC)
                                                                  recommends, ‘sufficient, long-term, ring-fenced
     On 23 April 2021 the Western HSC Trust suspended             funding for a Central Access Point’ to ‘ensure the
     their EMA service and ceased accepting referrals. The        continuation and effective delivery of a referral
     service had been maintained over the past year by a          pathway for termination services that upholds the
     single doctor working without any support. In the            privacy and confidentiality of women and girls.’
     correspondence I received from the doctor regarding
     this she highlighted that this had taken both a mental       However, ICNI’s requests for funding from the

20    BEYOND DECRIMINALISATION
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